PRIVACY POLICY

Neo-banking Platform

This Privacy Policy (“Policy”) which is effective from Sep 27, 2019,
provides information about how we, Cowper Labs Private Limited, a company
incorporated under the Companies Act, 2013 having its corporate office at
C-10, 1st C Main Road, Block-6, Sector 6, HSR Layout, Bengaluru, Karnataka
560102 ("Company") collect, use, store, share, transfer and
disclose your information/data (used interchangeably hereafter) when you
use the mobile application called “Wizely” that the Company has developed
and operates.

Wizely is a proprietary mobile application developed, operated and managed
by Wizely, whereby Wizely brings the “Neo Banking Experience” for India’s
150M+ young and emerging consumers. Neo Banking means a platform which
delivers an intelligent banking experience in partnership with an
ecosystem of traditional banking partner and non-traditional financial
service providers on one platform, that is simple, engaging and contextual
to the customer's financial life.

The Wizely application when downloaded on your smartphones provides a user
with a neo-banking platform (“Platform”). The Platform enables registered
users in availing banking products and services from different banking and
other financial services providers who partner with us (“Platform
Services”). The Platform Services facilitates opening savings bank
accounts, conducting banking transactions through the Platform, availing
loan and overdraft facilities through our partners (“Partners”).

Your privacy is important to us and appreciate your trust in us. In this
Policy, references to “you”, “your” or “user” shall mean the end user who
accesses Wizely and avails its Services. References to “we”, “us” and
“our” shall mean Wizely.

PLEASE READ THIS ENTIRE POLICY CAREFULLY. BY REGISTERING OR ACCESSING OR
USING OUR PLATFORM IN ANY WAY, YOU AGREE THAT YOUR INFORMATION MAY BE
COLLECTED, USED, STORED, SHARED, TRANSFERRED AND DISCLOSED AS DESCRIBED
IN THIS POLICY. IF YOU DO NOT AGREE TO ALL THE TERMS OF THIS POLICY, WE
RECOMMEND THAT YOU DO NOT USE THE PLATFORM.

BY USING THE SERVICES OR BY OTHERWISE PROVIDING US WITH YOUR
INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO
THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO
BE BOUND BY THIS PRIVACY POLICY. YOU HEREBY CONSENT TO OUR COLLECTION,
USE, SHARING AND/OR DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS
PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE
PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT
ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO
NOT USE ANY OF THE SERVICES OR PROVIDE US WITH ANY OF YOUR INFORMATION.
IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE OR AN ENTITY, YOU
REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO (I)
ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF, AND
(II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION,
USE AND DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS
DESCRIBED IN THIS PRIVACY POLICY

INFORMATION THAT WE COLLECT:

Wizely uses the Personal Information and other data that is collected for
the following general purposes:

Your personal information such as your name, date of birth, postal
address, e-mail address, mobile number etc which are required to be
provided by you at the time of registering on the Platform;

Fingerprint and PIN: You will be required to sign in to the Wizely
App using a PIN, which you will provide for while signing-up.
Additionally, you have an option to sign-in to the Wizely App with
your fingerprint. This is an additional security feature within
Wizely App, which you may opt for.

Any other information which would help determine your eligibility to
avail the services offered by us;

Your profile information such as your user name and password and
details about your activity on the Wizely App

Information which is required by our Partners to provide Services to
you;

Any other information that we are required to collect as per
specific mandate from any partner bank (“Partner Bank”) or other
Financial Services Company as per applicable laws such as any
information required to comply with the RBI mandated KYC norms (“KYC
Information”);

In addition to above, for mobile app: any other information that we
is required to collect in order to provide smooth mobile experience,
including but not limited to SMS access for auto- OTP verification,
camera/gallery/contacts access, for various functionalities within
the app.

Information we collect through your use of the Platform

Transaction Information: We may access banking and
financial transaction details related to your use within the
ecosystem of the Platform which includes bank account details,
one-time passwords, PIN transaction passwords, the date and time of
such transactions etc. to (i) provide you with customized content on
the Platform; (ii) monitor the Platform usage; and (iii) improve the
content and services provided on and through the Platform. We do not
store any banking transaction details on the Platform.

Activity Information:We collect information about all your activities on the Platform to
enable us to Service you better.

Device Information:When you visit or leave the Platform (including our plugins or
cookies or similar technology on the sites of others), Wizely
receives the URL of both the site you came from and the one you go
to next. Wizely also gets information about your IP address, proxy
server, operating system, web browser and add-ons, device identifier
and features, and/or ISP or your mobile carrier. Wizely will ask you
to opt-in before we use GPS or other tools to identify your precise
location.

Internet:Wizely will access the internet or wifi network or any changes in
the internet or wifi network of your mobile device for running the
Platform. The Platform can only be accessed on your web browser if
there is an internet connection.

Log Information:When you interact with the Platform, Wizely collects server logs,
which may include information like device IP address, access dates
and times, and other system activity, type of browser, and the
third-party site or service you were using before interacting with
the Platform to understand your usage of the Platform.

PURPOSE LIMITATION

Wizely uses the Personal Information and other data that is collected for
the following general purposes:

To deliver the Services made available through the Platform;

To curate specific Services for you;

To respond to the request that you sent us such as your request for
information, or your request to subscribe to a Service provided on
the Platform;

To administer, protect and improve the Platform;

To better understand the preferences of users of the Platform;

To identify server problems;

To compile aggregated statistics about usage of the Platform;

To help personalize your experience of the Platform;

To improve services offered to you;

To help Wizely in its internal business functioning;

To the extent permitted by applicable law, Wizely may combine
various types of data that is collected; and

Any other use Wizely may describe at the point when it collects
data.

STORAGE AND RETENTION OF YOUR INFORMATION

We retain your data for the duration of your use of the Platform. We
archive your data and store it to comply with any data requests by
Government authorities. We also retain the data for this period in order
to enable the users to re-start their account on the Application. We
retain your data for archiving purposes as well.

All KYC Information is only collected on behalf of our Partners including
the Banking Partner as mandated by applicable laws, for facilitating
authentication by such Banking Partner.
We do not process or store any KYC Information of the User.

SECURITY FOR YOUR INFORMATION

Wizely follows generally accepted standards to store and protect the
personal data we collect, both during transmission and once received and
stored, including utilization of encryption where appropriate.

We use HTTPS for secure transmission of data from end-user systems
to our cloud server.

All passwords are stored in database in encrypted format using AES
128 bit encryption.

DATA SECURITY BREACH

Transmissions over the Internet are never 100% secure or error-free.
However, Wizely takes reasonable steps to protect your personal
information from loss, misuse, and unauthorized access, disclosure,
alteration, and destruction. Wizely has implemented strict security
controls, intrusion detection software and processes to alert us in the
case of a potential or actual intrusion of our information systems. Wizely
has a data breach notification system in place and an established incident
response team that will react immediately and execute a remediation plan
in response to any unauthorized access to Wizely’s or the Platform’s
information systems or databases. If any data security breach occurs and
it may impact your personal information, you will be notified as soon as
possible once the breach has been determined.

ACCESS

If personal information you have submitted through the Platform is no
longer accurate, current, or complete, you are allowed to update these
changes using the Platform, but Wizely reserves the right to use
information obtained previously to verify your identity or take other
actions that it believes is appropriate.

COOKIES POLICY

Cookies are small pieces of identifying information, stored by your
browser on your PC and mobile, to enable information about your session on
the website/mobile application to be maintained. The cookie may contain
actual information (e.g. the date of your last visit), or just a unique
reference ID that allows the website to look up information about your
use.

If the Platform sets cookies routinely, these can also be used to track
your successive page views, and therefore your behavior on the Platform,
whether or not you are logged in. Unless you log in or complete an enquiry
form, such use of cookies will not enable the Platform to identify you
(because cookies can only give access to information that the Platform
already has). The Platform will not attempt to identify you unless you log
in.

Cookies set by one site cannot be read by another. However, one web page
may be made up of components (such as news stories, images or
advertising), some of which are delivered from third parties. Each of
those third-party sites will be able to set and read its own cookies on
any page where its content appears. Wizely allows other companies such as
web/mobile analytics partners to set or access their cookies or web
beacons or similar technologies on the Platform. For example, Wizely may
use third party mobile analytics partners to analyze big-data on its
behalf. These third-party analytics partners employ cookies, web beacons
and other similar technologies to measure and analyze the big-data. To do
so, these partners may use information about your use of the Platform
which information will be anonymized such that it cannot reasonably be
used to identify you. This data can also be used for online marketing
purposes by Wizely.

Cookies Usage

Wizely uses cookies, device finger printing, open device identifier number
or similar technologies to collect the information described above. Wizely
may also use the above mentioned technologies to: (i) provide you with
customized content on the Platform; (ii) monitor the Platform usage; and
(iii) conduct research to improve the content and services provided on the
Platform.

If you block cookies from the Platform, you will not be able to log in,
and a range of other functions, such as the tracking of new messages in
the discussion forums, will fail. However, you will be able to browse most
of the information on the Platform. The Platform uses some third-party
services, and you may need to consult their policies separately.

Using your browser to block cookies, and further information

Most browsers allow you to control cookies through their settings
preferences. However, if you limit the ability of websites to set cookies,
your overall user experience may get affected such as not having
customized access to the Platform. It may also stop you from saving
customized settings like login information. If you have questions about
our use of cookies, please contact
contactus@wizely.in

Third-Party Sharing

We share your personal information with third parties who perform
services on our behalf. We share information with vendors who help
us manage our online registration process or payment processors or
transactional message processors.

We share information with third parties and or business partners who
partner with us on the Platform. Each of the Partners have their own
privacy policies. The business partners will include banking and
other financial service providers and other partners on-boarded by
us onto the Platform.

We will share information with our other corporate entities and
affiliates. These entities and affiliates may market themselves to
you as a result of such sharing unless you explicitly opt-out.

We may share information if are required to do so by law. We will
share information to respond to a court order or subpoena. We may
also share information if a government agency or investigatory body
so requests. Or, we may also share information when we are
investigating potential fraud.

We may share information with any successor to all or part of our
business. For example, if part of our business is sold, we may
provide our customer list as part of that transaction.

We may share your information for reasons not described in this
policy. We will inform you before we do this. The collection,
storage and processing of data by the above third-parties either
pursuant to us sharing it with them or where you submit the data
directly, are subject to their own data protection policies and
security practices. We are in no way privy to the data protection
practices of these parties and is not responsible for their
adherence to data protection norms

We conduct from time to time contests for our users. We may use
third party service providers to collect and collate data for such
contests. We may share your information with such service providers
during contests.

CHILDREN’S PRIVACY

The Platform is intended for use by adults only. Wizely does not
intentionally or knowingly collect personally-identifiable information
from minors (under the age of 18) and requests that minors (under the age
of 18) do not submit any personal information on the Platform.

AMENDMENTS

Wizely reserves the right to change, modify, add or remove portions of
this Policy at any time, but will alert you that changes have been made by
indicating on the Policy the date it was last updated. When you use the
Platform, you are accepting the current version of this Policy as posted
on the Platform at that time. It is recommended that users revisit this
Policy on occasion to learn of any changes.

GREVIENCE OFFICER

If you have any questions, or concerns about this Privacy Policy or any
complaints or grievances about the manner in which Wizely handles your
personal information or the use of your personal information (in doing so
acknowledging that Wizely may be unable to provide you all or some of the
services), please feel free to contact the Grievance Officer any time at:

Note: You acknowledge and agree that merely un-installing the
Platform from your mobile device will not result in the deletion of
your information from the Platform and you will have to send an email
to contactus@wizely.in if you wish to have all your information
deleted from the Platform databases and servers.

THE USE OF THE PLATFORM OR ANY PART OF THE SERVICES ON THE PLATFORM,
EITHER IN WHOLE OR IN PART, SIGNIFIES YOUR AGREEMENT TO THIS PRIVACY
POLICY.